BlackRock Client and Vendor Privacy Notice

Last revised: 19 December 2019

Introduction

BlackRock is committed to processing personal information (“PI”), including sensitive personal information (“SPI”)1, in line with all applicable privacy and data protection laws. Most of our offices are located in countries with laws governing the processing of PI. “BlackRock”, “we”, “us” or “our” means BlackRock, Inc., and each of the direct or indirect subsidiaries of BlackRock, Inc. (the “BlackRock Group”). BlackRock, Inc., BlackRock Group functions and the entity you contract with are the controllers of your PI. If your contract with the BlackRock Group is in connection with an investment in a BlackRock managed vehicle, the management company of the fund, together with the fund entity and, in circumstances where the investment manager is part of the BlackRock Group, that investment manager, will be the controller.

References to “you” or “your” refers to individuals whose PI is processed by BlackRock, including clients with direct or indirect relationships (such as those who invest through an intermediary); employees, contingent workers, officers, agents (together “Representatives”); and beneficial owners of an organization or entity in connection with:

the provision of services to potential and actual clients;

transactions to which we are party (including those which we effect on behalf of clients); or

services provided to us by a third-party vendor.

This Privacy Notice sets out the purposes for which we collect, use and disclose (collectively “processing”) PI and how it is protected. It also sets outs individuals’ rights in relation to the processing of their PI.

There may be additional terms, conditions and commitments that also govern how we collect, use and disclose your PI, which should be read in conjunction with this Privacy Notice.

PI is information relating to an individual, which can be used either alone or with other sources of information to identify that individual. PI does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous. SPI is a sub-category of PI that includes PI relating to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.

The nature of the information that we collect will depend on the services we provide and our relationship with you. We categorize PI we process as follows (the PI listed for each category are non-exhaustive examples):

Technical data Your use of and interaction with our online services; your IP address; browser type and version; browser plug in types and versions; operating system

SPI In limited circumstances, and where allowed by law, we may collect information about criminal convictions and offences, when legally required; dietary requirements if we are arranging catering; disability so that we can make reasonable accommodations for you in our buildings; sexual orientation if you provide details of your spouse or partner; political affiliations for us to determine whether you are a politically exposed person.

We collect PI in relation to you in a number of ways, including:

when you provide it to us in connection with a BlackRock product or service, such as a completed investment application form

if you are Representative of an organization or entity that is a client or vendor of BlackRock and that organization or entity provides us with your PI

throughout the course of our relationship with you, including where you change your details, provide additional PI, or where the services we are providing to you change

from public sources where you have manifestly chosen to make your PI public, including via public profiles on social media

from third parties such as credit reference agencies

from visits to our websites or through logging into any of our online services

We may also create or derive PI such as creating records of your interactions with us, subject to applicable law.

Unless we otherwise indicate that the provision of specific PI is optional, any PI we request is necessary for us to provide you or your organization or entity with the products and services requested. If you do not provide the PI requested, we may not be able to provide those products and services.

Purpose and legal basis for processing your PI

The below table sets out the purposes and basis for which we process PI.

Processing Purpose

Category of PI

Basis of Processing

To consider opening an account, or entering into a relationship at your request, including performing anti-money laundering, anti-terrorism, sanction screening, fraud and other due diligence checks

Identification data

Contact data

Financial data

Professional Information data

Services data

SPI

Performance of a contract

Legal or regulatory obligation

Legitimate interests: ensuring we do not accept the proceeds of criminal activities or assist in fraudulent or any unlawful activities, such as terrorism

To deliver the services you have requested, including liaising with third parties (e.. brokers for the purposes of executing transactions) and to provide access to our technology solutions services (e.. Aladdin)

Identification data

Contact data

Financial data

Profile data

Services data

Technical data

Marketing and Communications data

Professional Information data

Performance of a contract

Legal or regulatory obligation

Legitimate interests: ensuring that you are provided with the best client services and visitor services we can offer, and securing a prompt payment of any fees, costs and debts in respect of our services

To manage payments, fees and charges and to collect and recover money owed to us

Identification data

Contact data

Financial data

Professional Information data

Services data

Performance of a contract

Legitimate interests: ensuring we can manage payments, fees and charges and to collect and recover money owed to us

To manager our relationship with you which will include notifying you about changes to our terms of business or this privacy notice

Identification data

Contact data

Profile data

Marketing and Communications data

Professional Information data

Performance of a contract

Legal or regulatory obligation

Legitimate interests: ensuring we can notify you about changes to our terms of business or this notice

To interact with governmental or regulatory bodies or other competent national authorities

Identification data

Contact data

Financial data

Services data

Professional Information data

Legal or regulatory obligation

Public interest

To detect or prevent fraud and/or other criminal activity and to protect our employees and assets

To send you marketing (including by paper and electronic channels) communications and service updates.

Identification data

Contact data

Profile data

Technical data

Marketing and Communications data

Professional Information data

Legitimate interests: reviewing how clients use, and what they think of, our services; identifying ways to improve and expand our business

In relation to vendor services:

Purpose and/or activity

Type of data

Legal basis for processing

To engage you or the organization or entity you work for as a new supplier, including performing anti-money laundering, anti-terrorism, sanctions, fraud and other background checks

Identification data

Contact data

Financial data

Services data

Professional Information data

Performance of a contract

Legal or regulatory obligation

Legitimate interests: ensuring we do not deal with proceeds of criminal activities or assist in any other unlawful or fraudulent activities for example terrorism

Public interest

To manage payments, fees and charges and to collect and recover money owed to us

Identification data

Contact data

Financial data

Professional Information data

Services data

Performance of a contract

Legitimate interests: ensuring we can manage payments, fees and charges; to collect and recover money owed to us

Where we provide you access to our systems we need to manage and protect our business, including improving data security, troubleshooting data and systems, system maintenance and testing, and data hosting

In connection with one or more of the purposes outlined in the section ‘Purpose and Legal basis for processing your PI’ above, we may disclose PI in any jurisdiction to:

other members of the BlackRock Group;

professional advisors, third parties, agents or independent contractors that provide services to any member of the BlackRock Group (such as IT systems providers, platform providers, financial advisors, brokers, consultants (including lawyers and accountants);

goods and services providers (such as providers of marketing services where we are permitted to disclose your personal information to them); intermediaries, brokers, and other individuals and entities that partner with us;

competent authorities (including any national and/or international regulatory or enforcement body, agency, court or other form of tribunal or tax authority) or their agents where BlackRock is required or allowed to do so under applicable law or regulation;

a potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of BlackRock’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it;

credit reference agencies or other organizations that help us to conduct anti-money laundering and anti-terrorist financing checks and to detect fraud and other potential criminal activity; or

any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument.

International transfers and transfers to service providers

To provide global services and in the course of running our business, we may transfer PI to a location outside of the country where you reside or where services are provided to you or the organization or entity you work for, including BlackRock processing centers in the USA, Hungary, India and Singapore. Although the country to which PI may be transferred may not have the same level of privacy and data protection laws, we apply the same level of security and organizational controls to the processing of PI wherever it is processed. We require by contract that our third party service providers processing PI on our behalf to comply with BlackRock’s criteria for PI processing.

If we transfer PI out of the EEA, we ensure a similar level of protection for your PI by ensuring the country to which the PI is transferred is considered by the EU Commission to provide an adequate level of protection, putting in place contractual clauses the EU Commission consider to provide the same level of protection. For third party service providers in the US, we may rely on the EU-US Privacy Shield certification.

Marketing and exercising your right to opt-out of marketing

We will not process your PI for marketing purposes if you have informed us you do not wish to receive marketing materials. You can request that we stop processing your PI for marketing purposes at any time by clicking on marketing opt-out links in any electronic marketing materials we send you, by making a request to your usual BlackRock contact or by using the contact details set out in the “Contacting Us” section of this Privacy Notice.

Third-party marketing/sale of PI

We do not share or sell your PI to third parties for the third party to use for their own marketing or other purposes.

PI retention

We will process your PI for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defense of legal claims.

PI security

We use a range of physical, electronic and managerial measures to ensure a level of security appropriate to the risk of PI processing. These measures include:

education and training of relevant staff to ensure they are aware of our privacy obligations when processing PI as well as training around social engineering, phishing, spear phishing, and password risks;

the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;

the ability to restore the availability and access to PI in a timely manner in the event of a physical or technical incident;

The security of data transmitted over the internet (including by e-mail) cannot be guaranteed and carries the risk of access and interception. You should not send us any PI by open/unsecure channels over the internet. We endeavour to protect personal information but cannot guarantee the security of data transmitted to us or by us.

Your rights

In certain circumstances you may have the following rights in relation to the processing of your PI:

Access To request a copy of the PI we process in relation to you and to be informed about how we use and share your PI.

Object To object to the processing of your PI if (i) we are processing your PI on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) if we are processing your PI for direct marketing purposes

Correction To request that we update the PI we process in relation to you, or to correct PI that you think is incorrect or incomplete.

Erasure To ask that we delete PI that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it.

Restriction To request that we restrict the way in which we process your PI, for example, if you dispute the accuracy of your PI or have raised an objection which is under consideration.

Portability To request a copy of your PI that you have provided to us in a commonly used electronic format such as through the completion of an application form.

Automated decision making To request manual intervention if you are subject to automated decisions where the decision results in a legal or similar effect to you.

You may exercise your rights at any time by using the details set out in the Contacting us section. To the extent permitted by applicable law or regulation we reserve the right to charge an appropriate fee in connection with you exercising your rights.

We may need to request specific information from you to help us confirm your identity and ensure your right to access to the PI requested, or to exercise any of your other rights. This is to ensure that PI is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us to locate the PI processed in relation to you, including, for example, the nature and location of your relationship with us.

We aim to respond to all legitimate requests within one calendar month. If we think it may take us longer than one calendar month, (such as where your request is particularly complex or you have made a number of requests), we will notify you and keep you updated.

You will not be disadvantaged in any way by exercising your rights in relation to the processing of your PI.

Contacting us

The Global Head of Privacy and Data Protection oversees compliance with privacy and data protection at BlackRock. If you wish to exercise any of your rights, or have questions concerning this notice, please contact:

If you are a California resident, you may also call us on +1 855 371 0019.

Complaints

If you have any concerns or complaints about the way your PI is processed, please contact the Global Head of Privacy and Data Protection at GroupPrivacy@BlackRock.com. You also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue in relation to the processing of your PI has arisen. Please contact GroupPrivacy@BlackRock.com for further details.

Cookie Notice

Please see our separate Cookie Notice.

Linked websites

This Privacy Notice is not applicable to third party websites that we do not own or control, or to any third-party website where BlackRock advertisements are displayed.

Changes to this Privacy Notice

We may modify or amend this Privacy Notice from time to time and you are advised to visit our website regularly to check for any amendments. Any material changes will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

BlackRock Cookie Notice

Last revised: 11 May 2018

What are cookies?

Cookies are small text files that are stored in your computer’s memory and hard drive, in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties which receive data obtained from that website.

When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.

Why do we use cookies?

Cookies help us to provide customized services and information. We use cookies on our Website to tell us, in general terms, how and when pages on our Website are visited, what our users’ technology preferences are – such as what type of video player they use – and whether our Website is functioning properly. Depending on their purpose, some cookies will only operate for the length of a single browsing session, whilst others have a longer life span to ensure that they fulfil their longer-term purposes (as explained in more detail below). Please note that, however long the cookies’ active life may be, you can delete cookies (and therefore stop any further data collection by them) as further described below.

If you are using one of our password-protected sites, then the Website may use cookies or other technology to help us authenticate you, store and recognize your configuration and user attributes, facilitate your navigation of the website and customize its content so that the information made available is likely to be of more interest to you.

In broad terms, we use cookies on our Website for the following purposes:

Analytical purposes Analytical cookies allow us to recognize, measure and track visitors to our Website and compile a record of this usage information. This helps us to improve and develop the way our Website works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of websites that are of the most interest to them.

Usage preferences Some of the cookies on our Website are activated when visitors to our sites make a choice about their usage of the site. Our Website then ‘remembers’ the settings preferences of the user concerned. This allows us to tailor aspects of our sites to the individual user.

Terms and conditions We use cookies on our Website in order to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to the terms and conditions on our Website. This helps to improve the user’s experience of the site – for example, it aids in avoiding a situation where a user is asked repeatedly to consent to the same terms. We also track whether a user has seen other similar documents (such as an online survey) before – again, to ensure that a user’s experience of our Website is a smooth one.

Session management The software that runs our Website uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, to authenticate users, and to determine what features of the site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for the site to function.

Functional purposesFunctional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.

AdvertisingAdvertising cookies allow us (or third parties) to monitor the behaviour of users of our Website. This information is used to ensure that products and services highlighted to those individuals are targeted in a focused and relevant manner – e.g. through advertisements on BlackRock websites or through advertisements on third party websites (e.g., Bloomberg, Agefi.com, Handlesblatt.de, etc) which are based on your experience with our Website; or to monitor the effectiveness of those digital marketing campaigns. We also monitor whether the adverts displayed on our Website are of interest to users and retain this information to ensure that adverts seen by users of our Website over a period of time are appropriate.

Please note that third parties may use cookies. The kind of cookies and the consequent data processing carried out by such third parties are regulated by their privacy policies. Please see below for more information about third party cookies.

Your cookie preferences

Cookies are necessary in order for you to be able to make full use of BlackRock’s Website. In addition, cookies help us provide you with personalized features on our Website. If you chose to disable cookies, some of BlackRock’s Website’s functionality might be impaired.

Local Flash Storage

On certain pages of our Website, we include content designed for display using Adobe Flash Player, such as animations, videos and tools. Local flash storage (often referred to as “Flash cookies”) can be used to help improve your experience as a user. Flash storage is retained on your device in much the same way as standard cookies but is managed directly by your Flash software.

If you wish to disable or delete information stored locally in Flash, please see the documentation for your Flash software, located at www.adobe.com. Please note that, if you disable Flash cookies, some site functionality may not work.

Third party cookies

When you visit our Website, you may receive cookies that are set by third parties. These may include cookies set by Google, Bizo, LinkedIn, AppNexus, Xaxis, MediaMind and/or Rocketfuel. These cookies are used for the purposes described in the “Why Do We Use Cookies?” section of this policy. We do not control the setting of these third-party cookies, so we suggest you might wish to check the third party websites for more information about their use of cookies and how to manage them.

If you wish to remove cookies set by our Website from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Please note, however, that withdrawing your agreement to the use of cookies on our sites will impair the functionality of the sites.

The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used browses, or you may consult the vendor documentation for your specific software.

Further information about cookies

If you would like to find out more about cookies in general and how to manage them, please visit www.allaboutcookies.org.